Responsible banking in practice

Human Rights Report 2016

Preface

ABN AMROand Human Rights

Our path towards respecting

human rights

I recently travelled to China for meetings with existing

and prospective clients. One of the objectives of my

visit was to find out how these companies perceive

their responsibility to respect human rights. Discussions

of this kind are not always easy. Like many other companies

around the world, they have only just begun to discuss

human rights issues with their contractors and suppliers.

And the banks they do business with tend not to

address human rights.

ABN AMRO is committed to respecting human rights.

As a full-service bank in the Netherlands with selective

corporate and private banking operations abroad we

are active in sectors and countries where human rights

abuses may occur. While we act with care and do

human rights assessments before and during our client

relationships, we cannot guarantee that we only finance

or invest in companies that fully respect human rights.

We always demand action when we learn about

violations or when we see that our clients are unaware

of the risks. People should not be disadvantaged by

the way in which we or our clients make money.

Doing business means taking responsibility.

This Human Rights Report is not only about how we

deal with the human rights risks to which companies

we finance or invest in are exposed. As a bank, we want

to uphold human rights in our own operations as well.

Everyone in society has the right to non-discriminatory

access to financial services. Clients entrust us with their

personal and financial data and we have a responsibility

to respect their privacy. As an employer with over

21,000 employees in twenty countries we want to make

sure that every single one of them is aware of their

fundamental labour rights. If local governments restrict

trade union rights or discriminate against lesbians, gays,

bisexuals and transgenders, ABN AMRO cannot simply

ignore this.

The publication of this report marks an important

milestone in our efforts to revisit all our operations from

a human rights perspective. We report what we have

done in this area and what we are proud of, and we also

describe the dilemmas we face and where more work

is needed. Embedding respect for human rights within

the bank is an ongoing process. Changes in our business

and society as a whole require us to continuously monitor

where and how we impact human rights, decide where

we draw the ‘red line’, and identify opportunities for

positive change. ABN AMRO is the first bank to have

committed to report according to the UN Guiding

Principles Reporting Framework. We hope that others

will follow suit. Every company is different; a bank

from the Netherlands will focus on other issues than

an energy company from China. But they both have

a responsibility to do business in a way that respects

peoples’ human rights, has a positive impact on their

lives and contributes to a more sustainable world.

Caroline Princen

Member of the ABN AMRO

Managing Board

‘ Changes in our business and society as a whole require us to continuously monitor where and how we impact human rights, decide where we draw the ‘red line’, and identify opportunities for positive change.’

Table of contents

4 Introduction

8 Salience

10 Our salient issues and roles as a bankOur role as a service provider 12

Our role as an employer 19

Our role as a lender 23

Our role as an investment services provider 32

38 Remedy

40 Looking to the future

42 ReferencesThe UN Guiding Principles Reporting Framework Index 42

List of abbreviations and important terms 43

Important online sources 43

3

Who we areABN AMRO is a full-service bank with a primary focus on the Netherlands and selective operations internationally. We serve retail, private and corporate banking clients based on our in-depth financial expertise and extensive knowledge of numerous industry sectors.

Our global presenceABN AMRO is present in 11 countries within Europe and 9 countries in Asia, North and South America and the Pacific. A complete overview of our global activities is provided online.

Introduction

The bank’s

21,000 employees serve:

5 millionindividuals and families

300,000small businesses

70,000 large businesses

Our portfolio at 30 September 2016:

Total investments:

146.2 billion euros (on behalf of clients)

Total financing:

269 billion euros

IntroductionHow we can affect peopleOur products and services have an impact on society.

We directly affect the lives of over 5 million people, as a

service provider and as an employer. Indirectly, in our

role as a lender and in providing investment services

and products, our impact is even larger. To explain our

impact more clearly, we have framed this report around

these four roles: service provider, employer, lender,

and investment services provider.

While we are committed to making a positive

contribution to society and to respecting human rights,

we acknowledged in our 2015 ABN AMRO and Human

Rights Guide that ABN AMRO may also be connected

to practices that harm human rights. We believe it is

important for a bank to look at its business operations

from this perspective. In this report we explain what this

means for ABN AMRO, and how we take responsibility

to meet our commitment.

According to the UN Guiding Principles on Business

and Human Rights – the global authoritative standard

on business respect for human rights - businesses

can be connected to negative human rights impacts in

three ways. Companies - banks included - may (1) cause

an adverse impact, (2) contribute to an adverse impact,

or, alternatively (3) their operations, products or services

may be directly linked to an adverse impact by a company

with which they have a business relationship. Each of

these three scenarios requires a different approach to

addressing, preventing or mitigating adverse human

rights impacts.

The ‘cause, contribute, linked to’ scenarios play out

differently for the four roles described in this report.

Moreover, it is not always clear when ‘linkage’ becomes

‘contributing’, or when ‘contributing’ becomes ‘causing’.

This is particularly the case when it comes to banks’

responsibility to address the human rights impacts

of the companies they finance, or invest in on behalf

of clients.

We hope that the responsibility of banks across their

different roles will be further clarified as more financial

institutions formulate their policy commitments, discuss

their dilemmas and different scenarios with stakeholders,

and report according to the UN Guiding Principles

Reporting Framework (UNGP Reporting Framework).

About this reportThis report is ABN AMRO’s first formal Human Rights

Report. It is a first step towards demonstrating how

ABN AMRO manages its impact on human rights.

2015 marked the start of our reporting journey on human

rights. In that year, ABN AMRO announced that it would

be reporting on its ongoing efforts to implement policies

and practices to respect human rights by applying the

UNGP Reporting Framework. This framework helps us

to do so in a transparent manner, while at the same

time acting as a management tool to identify gaps,

set priorities and continuously improve the management

of our salient human rights issues. The report will

also serve as a basis for further engagement with

our stakeholders.

6

Introduction

Please refer to our UNGP RF Index

on page 42 for related information

Structure of this reportThe UNGP Reporting Framework consists of three parts:

(A) Governance of respect for human rights, (B) Defining

the focus of reporting and (C) Management of salient

human rights issues. So far, ABN AMRO’s Human Rights

Guide and Annual Report 2015 have been the bank’s

two most important publications about the progress we

have made in respecting human rights. Their focus was

on the bank’s governance (A) and on defining its salient

human rights issues (B).

The focus of this Human Rights Report is on part (C),

and addresses the question: how does ABN AMRO

manage its salient human rights issues? It shows

where ABN AMRO stands and the steps it intends

to take. The report gives both practical examples and

descriptions of systematic and severe risks. The examples

do not necessarily illustrate an instance of severe impact,

but they do exemplify situations that we believe may

occur more frequently and that, taken together, could

possibly have a severe impact.

Internal engagement and setting prioritiesUsing the UNGP Reporting Framework for

this Human Rights Report also helped us to

create internal awareness and engagement.

More than thirty ABN AMRO employees were

interviewed about their work and related

salient human rights issues. The material

gathered during these interviews was

subsequently presented to internal and

external stakeholders for review in two

workshops. Based on their feedback,

we fleshed out the results, examples and

dilemmas presented in this report with

a view to enhancing its relevance and quality.

7

A focus on salient human rights issues

Listening to our stakeholdersIn October 2015, with support from Shift, the non-profit

centre of expertise on the UN Guiding Principles on

Business and Human Rights, we conducted an internal

analysis to identify the bank’s salient human rights

issues. During an internal workshop, experts from

different business lines and support departments

representing the entire bank together identified our

most salient human rights issues. From a list of potential

human rights impacts, based on ABN AMRO’s business

profile and an analysis of the severity and likelihood

of potential adverse impacts, participants prioritised

what they saw as the bank’s salient issues.

Following this internal process, the identification of our

salient issues was further informed by feedback from

external stakeholders. We surveyed participants at the

ABN AMRO International Human Rights Conference 2015

on whether they agreed with our selection of four salient

issues: privacy, discrimination, labour rights and land-

related human rights. We also received feedback

from stakeholders during an expert meeting held in

September 2016 to discuss the content of this Human

Rights Report. While a large majority agreed with our

selection, some shared additional issues for us to

consider. Defining and identifying salient human rights

issues is an ongoing process in which we will continue

to involve both internal and external stakeholders, such

as employees, human rights experts, non-governmental

organisations (NGOs) and society at large.

SalienceWhat are salient human rights issues? We need to focus our attention on the most

severe risks to people and prioritise our

resources accordingly. Salient human rights

issues, in the language of the UN Guiding

Principles Reporting Framework, are ‘the human

rights at risk of the most severe negative

impact through the company’s activities and

business relationships.’ The degree of severity

is based on the scale, scope and extent

to which the impact can be remedied.

A video on the website of the UNGP Reporting

Framework explains the concept of salience

further.

8

Salience

Salience

Please refer to our list of online sources

on page 43 for related information

In this report the four salient issues are further specified

under each of ABN AMRO’s four roles. We acknowledge

at the outset that this first report has some limitations.

Our employees’ right to privacy is included in our list of

salient issues, but only marginally addressed. And while

the scope of our International Framework Agreement

includes people who work for ABN AMRO via insourcing

or outsourcing contracts, this report deals only with

country risk and not with the question how we guarantee

that the human rights of all groups within ABN AMRO’s

workforce are fully respected.

Governance of our salient human rights issuesIt is ABN AMRO’s ambition to be a better bank contributing

to a better world. Our Human Rights Statement articulates

our general policy commitments to respect human

rights and the expectations we have of the businesses

we serve and those we work with. The ABN AMRO

Managing Board is ultimately responsible for our human

rights programme. This means that the Board signs off

on policy decisions, such as our International Framework

Agreement (explained in ‘Our role as an employer’).

Occasionally it discusses instances of adverse human

rights impacts of our clients. There are two bodies that

support the Managing Board on governance issues.

In 2015, ABN AMRO established an Ethics Committee,

which considers dilemmas that cannot be resolved in

other formal consultative structures. Employees who are

grappling with situations for which laws and regulations

or other internal committees do not provide a clear-cut

answer can submit their dilemmas to the Ethics

Committee. The committee is composed of two

members of the Managing Board, including the CEO,

and representatives from various parts of the bank.

It discusses complex dilemmas faced by the bank,

whether in relation to the bank’s own activities or

relationships with clients. These could relate to one

of the four salient human rights issues, such as

discrimination, but this is not necessarily the case.

In 2016 we established a new bank-wide human rights

platform under the chairmanship of a member of the

Managing Board. The platform will discuss the progress

and challenges that ABN AMRO encounters in its human

rights programme, structured by the four salient issues,

and will report its findings to the Managing Board on a

quarterly basis. It will be supported by various parts of

the bank that are involved in implementing our human

rights programme, such as the Privacy Office, the

Diversity Desk, and the Sustainable Banking Department.

This process resulted in the following list of salient human rights issues, which was included in our Annual Report 2015:

Privacy – abuse or loss of client

data, by ABN AMRO or third parties

Discrimination – in the provision

of services to (potential) clients

or against ABN AMRO staff

Labour rights – of ABN AMRO’s

own workforce, and the supply chain

workforce of corporate clients and

companies we invest in on behalf

of private clients

Land-related human rights – of

local communities and indigenous

peoples in relation to corporate

clients or companies we invest

in on behalf of private clients

9

Our salient issues and roles

In our four roles, we directly or indirectly have an impact on

human rights.

PrivacyAbuse or loss of client data,

by ABN AMRO or third parties

DiscriminationIn the provision of services

to (potential) clients or against ABN AMRO staff

Land-related human rights

Local communities and indigenous peoples in relation to corporate clients or companies we invest in on behalf of private clients

Labour rightsABN AMRO’s own workforce, and the supply chain workforce

of corporate clients and companies we invest in on

behalf of private clients

10

Our salient issues and roles as a bank

Our salient issues and roles as a bank

Our role as a Service provider

ABN AMRO is one of the largest retail banks in the Netherlands. We provide a broad range of financial services to more than 5 million clients.

Our role as an Employer

ABN AMRO has more than 21,000 employees worldwide. People also work for ABN AMRO through employment agencies and outsourcing contracts.

Our role as a Lender

ABN AMRO serves over 500,000 corporate clients in numerous sectors, from small restaurants in the Netherlands to multinational energy companies in Asia.

Our role as an Investment services provider

ABN AMRO provides clients with products and services so that they can reachtheir investment objectives. We invest assets on behalf of our clients.

11

Employer

Service providerLender

Investment

services provider

Our role as a service provider

Policy commitment and actions In June 2014, the Dutch journalism platform De Correspondent published an article on the use of

client data by ABN AMRO. Clients who received child benefits for the first time received a letter

inviting them to open a children’s savings account. In addition, they could win a gift card and a

prize from a company specialising in children’s items. Since 2014, we have adopted more stringent

policies and procedures governing the requirements for when client data may be used for marketing

purposes. We do not merely consider whether something is legally allowed, but also whether

we consider it morally acceptable.

ABN AMRO’s Binding Corporate Rules are the cornerstone of the bank’s global policy commitment

on privacy of personal information. The document, which contains rules on how personal information

should be handled by the global ABN AMRO organisation, was approved by the Dutch Data Protection

Authority in 2012. Following the introduction of the Binding Corporate Rules, ABN AMRO set up

a Privacy Office to help identify, assess and manage privacy risks for the bank and its subsidiaries

and to make sure the Binding Corporate Rules are being adhered to.

Our clients’ privacy concerns do not only relate to the use of financial data for marketing purposes.

We also have a responsibility to prevent data leakages, and to make sure that our employees

do not review financial information out of curiosity, but do so only when it serves the client.

Privacy

Our role: ABN AMRO is one of the largest retail banks in the Netherlands. We provide a broad

range of financial services to more than 5 million clients.

Salient issues: Privacy and non-discriminatory access to financial services.

Who could be impacted: All individuals and families who are clients or would like to become

clients of ABN AMRO.

Example of our impact on privacy: ABN AMRO possesses a large amount of personal

information about its clients. ABN AMRO has a responsibility to prevent the abuse of data or breach

of data security by ABN AMRO staff or others.

Example of our impact on discrimination: Access to financial services is instrumental to

participation in society and the achievement of people’s goals. Loan applications should be

assessed on ability to repay, not on potentially discriminatory factors such as ethnicity, gender

or postal codes.

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Our salient issues and roles as a bank / Our role as a service provider

Our role as a service provider

ABN AMRO is committed to protecting the privacy of its clients and staff. To formalise this commitment, it has adopted Binding Corporate Rules (BCRs). This means that the strict European Privacy legislation is upheld within the ABN AMRO Group worldwide. In 2015, the bank performed a global privacy self-assessment in 18 countries and at 20 subsidiaries. Some topics were identified that required improvement, but it generally confirmed that the BCRs are being followed, also outside Europe. A new European Data Protection Regulation will come into force in May 2018. To this end, ABN AMRO has initiated a global implementation programme that will further raise the level of privacy protection within the bank.

Our contribution to the fight against human trafficking includes: (1) raising awareness so our relationship managers and clients can recognise the warning signs and red flags of human trafficking, (2) conducting (supply chain) research together with our sector bankers, external stakeholders and experts to identify misconduct, and (3) improving intelligence sharing based on data analysis and expertise. This does not mean that we simply report an increasing number of suspicious transactions to the authorities. Instead, we use a holistic and targeted approach that has real impact.

Adriaan van Dorp

Director of Security &

Intelligence Management,

ABN AMRO

Frank Mulder

Chief Privacy Officer,

ABN AMRO

Stakeholder engagementAn important way to inform our approach on human rights issues is to discuss it with our

stakeholders. In 2015, ABN AMRO organised a stakeholder dialogue on security, stability and

privacy of financial transactions. This resulted in a set of recommendations. For example, the

participants stressed the importance of active engagement with clients. Furthermore, they felt

that clients should be able to make their own decisions concerning trade-offs between data

protection and the level of security and user-friendliness. In 2016, ABN AMRO continued its

engagement with stakeholders on a bilateral basis, both with internal experts and with NGOs

and consumer representatives. In these conversations we focussed on the possible roles the

bank could play as a service provider, such as our role in informing clients about changes in

legislation and possible consequences for their privacy. Another way in which we involve clients

in defining our approach towards privacy is by organising focus groups for all major developments

in digital banking.

Taking action on human traffickingWhile we make every effort to protect the privacy of our clients, strong privacy protection can,

in exceptional cases, have an adverse effect. Banks play an important role in the detection of fraud,

money laundering and other criminal activities. ABN AMRO is currently exploring what banks can

do to prevent the use of their own financial services for human trafficking purposes.

13

Employer

LenderInvestm

ent services provider

Service provider

DilemmaOur ability to tackle the financial infrastructure of the billion-euro human trafficking

industry depends on the collection and analysis of data. Also, during our 2016

stakeholder dialogue on labour exploitation, the participants made clear that

they expect ABN AMRO to use big data analysis for this purpose. At the same time,

however, we want to assure all our clients that we take their right to privacy seriously.

PrivacyAbuse or loss of client data,

by ABN AMRO or third parties

14

Our salient issues and roles as a bank / Our role as a service provider

Non-discriminatory access to financeNo-one should face discrimination when opening a bank account or applying for a loan.

Non-discriminatory access to financial services is therefore the second salient human rights

issue we identified for ABN AMRO in relation to its clients. Apart from non-discrimination being

a human right in itself, access to finance also enables the fulfilment of other human rights.

A bank account is often necessary to fulfil the right to work, for example. And if someone is denied

a mortgage because he or she lives in a disadvantaged neighbourhood, the right to an adequate

standard of living is at stake. Similarly, restrictions on trade union funds sometimes exercised

by governments are incompatible with the principles of freedom of association.

ABN AMRO aims to prevent discrimination in access to financial services in four areas: 1. Access to bank accounts

2. Loan applications

3. Product conditions

4. Communications

Access to bank accountsWe offer a range of financial products. A general distinction can be made between access to

checking and savings accounts and access to loans. In societies like the Netherlands it is impossible

to function without a bank account. Our policy in this regard is based on the 2001 Dutch banking

sector covenant to create a basic checking account agreed between, among others, the Ministry

of Finance, the Salvation Army and the Legal Aid Board. This is an account that can be opened by

people who in the past were excluded from financial services, like the homeless, asylum seekers,

and sex workers. For more information on access to bank accounts, please see page 18.

Loan applicationsStudies on discrimination in financial services often focus on redlining. This refers to the practice

of differentiating between people on the basis of where they live, rather than on their financial status.

Researchers have argued that this also occurs in the Netherlands. If it does, it is in contravention

of our human rights commitment. Whether or not someone is able to obtain a loan should depend

on his or her ability to repay it. Postal codes are not a valid proxy for credit risk.

15

Employer

LenderInvestm

ent services provider

Service provider

Some criteria used to determine the limits and conditions for a credit application are justified from

a credit risk perspective, but may nonetheless be perceived as being discriminatory, especially when

it affects vulnerable groups in society. For example, the maximum amount people can borrow for

a mortgage is lower for people with a temporary residence status than for permanent residents

of the Netherlands. This includes expats, but also refugees. Similarly, the decision by the Dutch

government to collectively reassess young people who claim disability benefits could in some cases

have negatively impacted their borrowing power. Where possible, ABN AMRO responds to the needs

of groups that have difficulty applying for credit. For example, we have made it easier for freelancers

and the self-employed to obtain a mortgage by looking at income security rather than job security.

When problems arise in this area, it is rarely a concern faced by ABN AMRO alone. Listening to

affected people or their representatives therefore typically takes place in cooperation with other

banks or with the Dutch Banking Association.

Product conditionsDuring the reporting period, ABN AMRO lost one case before the Netherlands Institute for Human

Rights (NIHR) that related to product conditions. This concerned a person with Spanish nationality

who was the sole shareholder of a Dutch company that operated only in the Netherlands. Because

client due diligence is more difficult for foreign clients and for complex corporate structures, these

clients are charged higher fees – and this client was charged the higher fee. The bank later acknowledged

that it should not have done so in this case because the company operated only in the Netherlands.

However, the acknowledgement came too late and the way in which the bank handled the complaint

was inadequate. For these reasons the NIHR concluded that discrimination had occurred.

This case led to a number of adjustments in our policies and procedures. The new complaints policy,

which is currently being developed, will deal with discrimination complaints as a separate category.

By explicitly registering these complaints as such, we will be able to better track our performance and

obtain the necessary management information. ABN AMRO’s Complaints Management Department

has also integrated the issue of discrimination in its presentations and training programmes.

This helps our front-office staff to be better aware of their responsibilities.

CommunicationsABN AMRO strives to ensure that everyone in society can understand our financial products and

services. This includes the illiterate, blind and deaf. For the latter group, for example, ABN AMRO now

offers advice in sign language by webcam.

16

Our salient issues and roles as a bank / Our role as a service provider

The participants in our internal workshop who identified our salient human rights issues also

included in their findings the privacy of our employees. For this first report we decided to focus

on how ABN AMRO is making an effort to protect the rights of workers in countries where local

laws limit our ability to do so. This does not mean that privacy of employees is not a concern.

Margot van Kempen

ABN AMRO

Employee Council

Tracking performance on privacy and non-discriminatory access to financial servicesIn 2015 ABN AMRO introduced a closed loop feedback

system for retail clients. After a client has had contact

with an ABN AMRO employee, for example to discuss

mortgages at a local branch, he or she is asked to fill out

a questionnaire. The client is then contacted to discuss

the feedback, and ABN AMRO staff look whether there

is an opportunity to improve the process or outcome.

The data collected through this system can also identify

systemic issues related to privacy or discrimination.

In October 2016, we conducted an initial scan on privacy

and discrimination-related customer feedback. This scan

identified concerns about the open set-up of our local

branches, in which some clients reported that they

did not feel comfortable discussing banking matters

because they might be overheard. We received no

significant feedback with regard to discrimination.

ABN AMRO also tracks the number of complaints that

are handled by the central Complaints Management

Department. Client complaints about non-compliance

with our privacy guidelines in the Netherlands are

reported in our Annual Report. Fifty complaints were

filed in 2014, three of which were upheld. For 2015,

the number of complaints increased to fifty-six, of which

10 were upheld. Complaints that relate to discrimination

are not reported separately, but we plan to do so in

the future.

With the rapid pace of digitalisation, employees’ privacy is slowly being nibbled away at. Going against employees’ privacy is permitted only if the bank has compelling reasons for doing so. Digital staff monitoring systems are used to monitor whether employees comply with applicable laws, rules and codes of conduct. Those that do not can be identified and reprimanded at an early stage. The Employee Council has the right of consent in these issues and always considers whether there is a compelling reason for a certain action. It also gives its opinion on such matters as providing information in advance, restricting the data that can be monitored, and keeping the number of people who have access to the monitoring results to a minimum. In my experience, the bank sets great store by protecting the privacy of its employees and is open to our suggestions for improvement.

17

Employer

LenderInvestm

ent services provider

Service provider

An example from the fieldIn 2016, someone was denied a bank account at an ABN AMRO branch in the Netherlands because

he held a passport from a country subject to international sanctions. However, these sanctions only

apply to certain sectors and to certain individuals and companies from that country. The refusal

was therefore unjustified. This example shows that discrimination can occur unintentionally because

an employee of the bank does not want to risk creating a compliance problem. There are no quick

fixes, but we will examine what we can do to minimise the risk that this will happen again.

DiscriminationIn the provision of services

to (potential) clients

18

Our salient issues and roles as a bank / Our role as a service provider

Our role as an employer

Labour rights and workplace discriminationEnsuring decent working conditions for people who work for ABN AMRO requires different measures

depending on (1) whether or not they are directly employed by ABN AMRO, and (2) whether or not

they work in countries that respect labour rights and other human rights. People do not readily think

of banking as a profession that is vulnerable to human rights violations. But having offices in countries

like the United Arab Emirates gives us a responsibility to think about how our staff can voice their concerns

collectively, despite a national prohibition on trade unions. We also need to make sure that the rights

of our janitors and canteen cooks are respected, even though they may be employed by a third party.

This first Human Rights Report focuses on human rights risks that follow from the local context in

which the bank operates. Our commitment to address these risks is set forth in two documents:

our International Framework Agreement (IFA) and the LGBT statement of the Ethics Committee.

Our International Framework Agreement with the Netherlands trade union federation FNV and

the global federation of trade unions for skills and services UNI Global Union expresses our

commitment to respect basic labour rights in every country where the bank has a presence or

where people perform outsourced work for the bank. The IFA clearly states that it applies to

‘all workers producing products or services for ABN AMRO, whether or not they are employees

of ABN AMRO.’ In other words: it covers our CEO as well as a call centre employee who works

for a service provider of the bank outside the Netherlands.

Our role: ABN AMRO has more than 21,000 employees worldwide. People also work

for ABN AMRO through employment agencies and outsourcing contracts.

Salient issues: Labour rights and workplace discrimination.

Who could be impacted: All people working directly or indirectly for ABN AMRO.

Example of our impact: ABN AMRO should prevent discrimination in human resources

processes (e.g. promotion, salaries), ensure safe and healthy working conditions,

and not restrict the ability of people to join a trade union and bargain collectively.

19

Service providerLender

Investment

services providerEm

ployer

Our role as an employer

The IFA clarifies the basic rights these workers are entitled to, including: Å No discrimination or intimidation in employment

Å Freedom of association and assembly and the right to collective bargaining

Å Payment of living wages

Å Reasonable and legitimate rules relating to working hours

Å Decent working conditions

Å Good work-life balance

Å Freedom of expression

The local context of the country in which the employee works is an important factor influencing

whether these rights are respected. In some countries, ABN AMRO employees are organised

through staff councils. The mandate of the bank’s Employee Council in the Netherlands is laid down

in Dutch domestic labour law. The council is involved in major business decisions such as corporate

restructurings, but may also proactively raise concerns. In addition, we have good relationships with

trade unions. Membership levels in the financial sector are generally low. While unionisation in

the financial sector in the Netherlands is around 4%, there are ABN AMRO offices in which no one

is a member of a trade union. In many countries where we are active, unions play an important role

in negotiating collective labour agreements. The International Framework Agreement was initiated

by the FNV, which is represented in the IFA’s monitoring group.

In various countries where we operate, freedom of association and collective bargaining are

prohibited or restricted by law. The OECD Guidelines on Multinational Enterprises state that ‘in

countries where domestic laws and regulations conflict with the principles and standards of the

Guidelines, enterprises should seek ways to honour such principles and standards to the fullest

extent which does not place them in violation of domestic law.’ In our own Human Rights Statement

we also note that where national law conflicts with human rights responsibility, companies

must comply with national law while respecting the international principles. The means through

which we can put these statements into practice differs per country and per human rights issue.

For example, companies could support employees in collectively discussing employment-related

issues even when formal Employee Councils or trade unions are prohibited.

Having an IFA is merely the beginning of a process of change towards a situation in which doing business in compliance with human and labour rights is standard practice. This is not only good news for the employees of ABN AMRO, but also for the workers of the companies ABN AMRO finances or invests in. I urge the bank to recommend its clients to adopt an IFA. In other words: preach what you practice, ABN AMRO.

Beryl ter Haar

Assistant Professor of Labour Law,

Leiden University

20

Our salient issues and roles as a bank / Our role as an employer

Signing the International Framework Agreement is the start of a social dialogue. It does not provide

cut-and-dried solutions. After the IFA was signed, the document was distributed to the bank’s local

country executives and human resources officers. In 2016, we nonetheless learned of one incident

in which an ABN AMRO employee who transferred to a subsidiary in Asia was offered a contract

that explicitly prohibited trade union membership. This was clearly non-compliant with the IFA and

the contract was subsequently changed. In 2017, all foreign branches of ABN AMRO will conduct

a self-assessment to determine to what extent they comply with the IFA. In addition to reviewing

the content of contracts, we will also examine how we can track our performance on labour

rights issues over time. This will provide a basis for the IFA’s monitoring group, which consists

of ABN AMRO and trade union representatives, to determine which actions are necessary

to further improve our performance.

Lesbian, gay, bisexual and transgender rightsWhile the IFA covers non-discrimination in employment, the Ethics Committee adopted a specific

LGBT statement in May 2016 because of the severe impact of exclusion based on sexual orientation.

ABN AMRO wants to be a diverse and inclusive company. To support this goal, our employees have

established a Gay Bankers Network, which facilitates a platform where like-minded people can meet,

exchange experiences and grow their professional network within the organisation. The network also

serves as a forum for network members and the bank’s management on LGBT and related issues.

But not all of our LGBT colleagues can live their lives as they would like to. Same-sex sexual activity

is a crime in two countries where ABN AMRO has an office: Singapore and the United Arab Emirates.

ABN AMRO also has offices in Russia, China, Hong Kong and Japan where same-sex unions or

marriages are not allowed and where laws that prohibit LGBT discrimination are absent or extremely

limited. Sometimes, legislation also targets companies, for example by criminalising them for

knowingly employing LGBT people.

Secondments to an ABN AMRO office in an LGBT unfriendly country are always voluntary. But this

does not negate the bank’s responsibility to provide a safe and secure workplace. There is no evidence

to suggest that our employees have faced discrimination that ABN AMRO could have prevented or

mitigated. In its LGBT statement, the Ethics Committee determined that in order to mitigate adverse

impacts, ABN AMRO should deepen its knowledge of the law, culture and practices in the countries

in which it operates. On this basis we can discuss with our employees how they can work and live

safely. This requires pragmatic solutions in addition to policies. For example, spouses of ABN AMRO

employees in some countries are covered by the health insurance scheme offered by the bank.

In countries where same-sex marriages are not recognised, however, insurance coverage is not

possible for LGBT spouses. To provide the same level of health benefits, ABN AMRO could, for

example, compensate employees by increasing their salaries so they can independently buy health

insurance for their spouses. Finding pragmatic solutions to prevent discrimination is only a first step.

Where possible, ABN AMRO actively supports efforts to improve the situation of LGBT people.

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At ABN AMRO we believe that the rights and diversity of our employees should be respected. But this is not self-evident in all countries where ABN AMRO has a presence, such as in Hong Kong. With support from ABN AMRO’s Country Executive for Greater China we set up an LGBT team this year. The team organised activities at the office, sponsored events and drew attention to LGBT rights in Hong Kong. It shows how important it is to have the backing of management for these kinds of issues.

Alexander Peters

Reward Advisor,

ABN AMRO Hong Kong

A diverse workforce and an inclusive culture are not only important because it is the smart thing

to do from a business perspective, but also because it is the right thing to do. The Ethics Committee

therefore also noted that ABN AMRO will let LGBT-unfriendly countries know what our views are

on this topic. As ABN AMRO has no significant leverage on its own, we will cooperate with other

companies where possible. We also work with partners like Workplace Pride, an international platform

for LGBT inclusion.

Tracking performance on workplace discriminationThe Declaration of Amsterdam, a call to action on the improvement of LGBT rights in the workplace,

launched by the Workplace Pride Foundation in 2011 and signed by ABN AMRO, determines that

‘employers and employees should develop and establish measurements that identify the level and

progress of LGBT inclusiveness within the organization and benchmark this externally’. The bank’s

Employee Engagement Survey only contains a general question on whether ABN AMRO has an

inclusive business culture. Therefore, in 2013, we carried out a specific survey among all employees

in the Netherlands on general and work-related LGBT issues.

A crucial aspect of this survey was that employees were open about their sexual orientation.

However, given that some employees did not answer a number of sensitive questions, we inferred

that they were concerned about the guarantee of anonymity. Obtaining this information in countries

other than the Netherlands is even more difficult.

In the survey in the Netherlands, 6.5% of the respondents listed ‘other than heterosexual’ as their

sexual orientation. This provided the basis for follow-up questions about whether they were open about

this, the reasons for not being open, and whether they were bullied at work. A similar anonymous

survey was conducted at our office in France. There, none of the 80 employees identified as LGBT.

While this may be true, given broadly accepted data about the general percentage of people who

are homosexual or bisexual, we believe it is more likely that people felt uncomfortable answering

this question honestly. In other countries too, LGBT employees may have legitimate concerns that

anonymity is not guaranteed, which could have personal ramifications.

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Our salient issues and roles as a bank / Our role as an employer

Our role as a lender

Labour rights and land-related human rightsABN AMRO is committed to respecting human rights and requires the same from its business

clients. This means that ABN AMRO has a responsibility to identify potential human rights abuses

involving companies it finances, and uses its leverage to prevent and mitigate impacts on people.

Our role: ABN AMRO serves over 500,000 corporate clients in numerous sectors, from small

restaurants in the Netherlands to multinational energy companies in Asia. Our total lending

portfolio for corporate banking exceeds 88 billion euros.

Salient issues: Labour rights and land-related human rights.

Who could be impacted: All people who are directly or indirectly affected by the activities

of our corporate clients and in their supply chains.

Example of our impact on labour rights: In the Dutch construction and agriculture sectors

there have been various cases of labour exploitation. This often involves migrant workers.

Some companies withhold passports, or charge excessive rents, resulting in salaries well below

the Dutch minimum wage. Because we are aware of the risks in these sectors, we ask questions

to prospective clients.

Example of our impact on land-related human rights: Sometimes information on adverse

human rights impacts emerges after a company becomes a client of ABN AMRO. If we were to

find out that a client sources from a plantation that was previously inhabited by a community

that did not voluntarily consent to leave the area and where international standards were not

met when the community was resettled, we would have a responsibility to act by exercising

our leverage over the client.

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Our commitment to address labour rights and land-related human rights is embedded in our

Sustainability Risk Framework, in particular in our Sustainability Risk Policy for Lending. This policy

contains the standards and procedures we apply to assess the actual and potential human rights

impacts of our clients. All clients have to comply with the criteria that apply to our Exclusion List.

Although ABN AMRO favours engagement over exclusion, we revisit these criteria, and our

‘red lines’, on a regular basis. The Exclusion List clearly states that ABN AMRO will not knowingly

finance or invest in activities causing human rights violations. Other criteria that need to be adhered

to are:

Å Necessity of Free Prior and Informed Consent (FPIC) in activities resulting in resettlement

of indigenous and/or vulnerable groups

Å Mandatory membership of the multi-stakeholder Round Table for Sustainable Palm Oil (RSPO)

for palm oil clients

Å Compliance with the Kimberly Process for our clients in the diamonds sector

In addition to the Exclusion List, ABN AMRO has sector-specific policies. Project financing activities

are assessed according to the Equator Principles. Our sector-specific policies contain detailed

minimum and recommended standards of behaviour. For example, membership of the Bangladesh

Accord on Fire and Building Safety is a mandatory requirement for our textile clients. But we also

encourage them to join the Fair Wear Foundation, the Business Social Compliance Initiative, the

Ethical Trading Initiative, the Better Cotton Initiative or the Fair Labor Association. As the continuous

growth of the agriculture sector gives rise to human rights risks, our recently revised policy on agri-

commodities also places human rights centre stage. The sector-specific policies that do not yet

include human rights-related criteria will be revised.

Human rights due diligenceIn our role as a financier, effective management of our salient issues depends on the successful

identification and mitigation of human rights risks. ABN AMRO performs two types of human rights

due diligence in its lending portfolio: value chain studies and company assessments. First, the bank

identifies and assesses structural human rights impacts through value chain studies on diamonds,

textiles, cocoa and copper. The copper project focuses on the Democratic Republic of the Congo and

Zambia, where severe human rights impacts have been reported, both in large-scale mining and in

the artisanal and small-scale mining sector. This includes environmental degradation (which can have

a negative impact on communities), abusive working conditions and risks related to the deployment

of private security companies. Taking a value chain approach helps us to better understand the level

of risk associated with financing companies that are active in these sectors and how we can best use

our leverage.

Company assessments are a second way in which we perform our due diligence. The human rights

criteria are integrated into ABN AMRO’s regular client acceptance and credit frameworks. This means

that we assess all new clients, as well as existing clients applying for a new loan. In addition, we

perform event-driven reviews when a client is the subject of adverse media coverage or NGO reports.

ABN AMRO’s relationship managers bear primary responsibility for the implementation of policies

through client assessments.

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Our salient issues and roles as a bank / Our role as a lender

The assessments are based primarily on information provided by the existing or prospective client,

who responds to a questionnaire that addresses all issues mentioned in the relevant sector-specific

policy. These data are verified by information available in the public domain. ABN AMRO subsequently

assesses whether a company performs above, below, or on par based on benchmark criteria that

relate to commitment, capacity and track record:

Commitment: This category addresses the company’s policies, whether these policies apply

to suppliers and contractors, to what extent senior management is involved and how it engages

with stakeholders and with local communities in particular.

Capacity: This category addresses the company’s management system, training efforts, and

reporting.

Track record: This category assesses whether the company has faced serious incidents, stakeholder

or media campaigns and legal action on sustainability issues.

On the basis of this information, ABN AMRO decides whether or not to accept a client or approve

a credit proposal. In 2015 and 2016, multiple training sessions were organised in Netherlands,

the United States, Singapore, China and Brazil to familiarise our relationship managers with the

Sustainability Risk Framework and the tools that are used to assess whether our clients are compliant.

These sessions were attended by over 900 employees.

The consequences for large corporations that perform below par are different than for small and

medium-sized enterprises (SMEs). When a large corporation performs below par we either turn

it down or accept it with conditions, depending on the gravity of the case and the prospects for

improvement. For SME clients, comprehensive sustainability assessments have only been in place

since 2015. We are currently gathering data on our clients’ performance, but only in a limited number

of cases do we impose conditions or reject a credit proposal.

Commodity traders ship everything from copper to cocoa and from oil to oats. In the past, these companies focused primarily on health and safety conditions at their own operations. Nowadays, we see that leading companies recognise that they cannot ignore human rights abuses at the mines or plantations they source from. Responsible business also requires greater transparency. More and more companies are joining sustainability initiatives, like the Extractive Industries Transparency Initiative. And throughout their value chains, traders have to prevent and mitigate pollution incidents that damage the environment and impact the right to health of local communities. As their financier, ABN AMRO has a responsibility to distinguish leaders from laggards and take the dialogue on these important issues forward.

Brinn Lausberg

Relationship Manager

Commodity Finance,

ABN AMRO

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Our ‘red lines’ in practiceThe decision to accept or reject a client is made by various approval authorities within the bank.

The Compliance Department and the Sustainable Banking Department provide advice. In 2016,

at least one prospective client was turned down as its handling of a workers’ strike in Latin America

was found to be non-compliant with the criteria that apply to our Exclusion List. In another case,

a relationship with an existing client is in the process of being terminated as the client refused

to answer questions on allegations by a trade union about labour exploitation in the Netherlands.

At this time, the bank does not keep centralised records of prospective clients or credit proposals

that have been rejected on the basis of concerns relating to salient human rights issues.

Some proposals are withdrawn before they are submitted to the approval authorities, for example

because a relationship manager considers the human rights risks unacceptable.

DilemmaABN AMRO wants to be a trusted business partner for its clients. In line with

standard practice in the financial sector, we do not communicate about our

client relationships with third parties. This makes it difficult to be responsive to

NGO reports. For example, in the annual policy study of the Fair Finance Guide

ABN AMRO consistently obtains a high score on human rights and labour rights,

yet these scores are not confirmed in their ‘practice studies’. This is not because

ABN AMRO does not put its policies into practice, but because we cannot provide

all the information the Fair Finance Guide requires. There are some exceptions,

however. Trafigura, a commodity trader that has faced significant human rights

issues in the past but has since taken major steps to improve its performance

in this area, asked ABN AMRO to contribute to its 2016 Responsibility Report.

In this contribution, we outline our vision on the steps that companies in

the trading sector should take to strengthen their human rights performance.

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Our salient issues and roles as a bank / Our role as a lender

Imposing conditions and using leverageIn 2015 the Sustainable Banking Department imposed conditions on establishing or continuing

a lending relationship with 51 companies. Thirty-two of these were companies where we specifically

looked at human rights issues. In 2016 this number increased to 59 out of 102 companies. There are

three types of conditions:

1. Requests for more information or higher monitoring frequency. This occurs when there is

limited information on a company’s human rights policies but no reason to suspect adverse impact.

For example, a number of clients in the diamond sector have been asked to join the Responsible

Jewellery Council, or, if they are not willing to do so, to provide a well-substantiated explanation.

2. Demands for substantive improvements in a client’s policies or practices. When the issues

are not significant or may be easily resolved, we aim to bring the client into compliance with

ABN AMRO’s policies as soon as possible. This is a formal process with annual monitoring.

3. Commencement of an engagement procedure. When a client’s non-compliance with our policies

is significant, but we feel that we can contribute to positive change, the company is put on our

focus list. This sets in motion a formal engagement procedure, which is described on the next page.

From January 2017, we will be improving our data collection on our salient human rights issues.

This includes a review of the definitions we use. For example, an environmental spill can affect

land-related human rights and should be classified accordingly. In the next Human Rights Report

we hope to provide more detailed information on the number of conditions in each of these three

categories, as well as on their monitoring and progress.

Client engagement on human rightsThe formal engagement procedure begins by submitting the file to the Central Credit Committee or

the Managing Board to inform them about the issue. Successful mitigation of human rights impacts

depends on our clients’ ability and willingness to enter into a results-oriented process. When we

finance a company, there is usually potential for direct engagement. If not, for instance because we

participate in a loan syndicate with other banks, engagement could be performed by a third party.

The procedure is overseen by a team from the relevant business line and the bank’s sustainability

advisors. Progress reports are drafted on a quarterly basis and the Managing Board is informed

at least once a year.

If a company does not comply with ABN AMRO’s minimum standards within two, and in exceptional

circumstances three years, the client relationship is terminated. An extension of this timeline is only

possible when substantial improvements have been made and full compliance is within reach.

ABN AMRO hopes its efforts are increasing the likelihood that clients will address their human rights

impacts. But we can rarely be sure there is a causal relationship between engaging with our clients

and the actions these clients subsequently take to improve their management of human rights issues.

Often, ABN AMRO is one voice among a varied group of consumers, NGOs, other banks and

governments who pursue the same objective through different means.

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Engagement as a driver for responsible business

Determine engagement potential and

approach

Non-compliancewith

ABN AMRO standards

Step 1 Step 2

Define objectives of engagement

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Engagement as a driver for responsible business

Evaluate engagement

results

Engage with company

and monitorprogress

Step 3 Step 4

Engagement objectives achieved: company is compliant

Continue relationship and monitoring in line with regular procedures

Engagement objectives not fully achieved, but compliance within reach

Continueengagement trajectory

Engagement objectives not fully achieved, successful engagement not possible

End relationship with company

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DilemmaEngagement is not an end in itself. We believe that when necessary and feasible, it is worth

trying to improve the human rights performance of our corporate clients. Discussions should not

last indefinitely, however. We end our engagement when there is no, or too little improvement.

But this is difficult to determine and open to interpretation.

In the coming years ABN AMRO will be expanding its international presence. This will go hand in

hand with our efforts to address our salient issues, also in new client relationships and operations

in new countries. For example, in conversations with prospective clients in China, ABN AMRO

Managing Board member Caroline Princen explicitly raised our concerns on human rights.

International expansion will likely lead to engagement with more

companies. In parallel, we also intend to use this opportunity

to improve our management of human rights issues,

for example by integrating human rights conditions

into our loan documentation.

Land-related human rights

Local communities and indigenous peoples in relation to corporate clients or companies we invest in on behalf of private clients

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Please refer to our list of online sources

on page 43 for related information

Involvement of stakeholdersOur dialogue with stakeholders helps us to better understand and manage human rights issues

in the business of lending. For example, together with the Dutch NGO Solidaridad, ABN AMRO

authored a White Paper on ‘Due Diligence Procedures with respect to Land Governance’ to support the

implementation of the Voluntary Guidelines on the Responsible Governance of Tenure of Land (VGGT).

ABN AMRO regularly convenes thematic stakeholder dialogues. In September 2016, we organised

a dialogue that focused on labour exploitation in the Netherlands. Human rights violations occur not

only in Asian textile factories or African mines, but also in the agriculture, construction and temporary

employment sectors in the Netherlands. Given the large presence of ABN AMRO in the Dutch economy,

we wanted to learn what our stakeholders expect from the bank. That same month, two workshops

were organised in cooperation with the Dutch national police to train relationship managers on how

to identify irregularities and suspicious circumstances that might be indicative of labour exploitation.

Contrary to the situation in the Netherlands, it is difficult to engage with affected stakeholders or

their legitimate representatives on human rights issues that occur in our clients’ foreign supply

chains. This is caused by a lack of geographical and business proximity, but also by the scope

and size of ABN AMRO’s lending portfolio. We have started to bridge this gap in several ways:

Å We ask clients whether and how they engage with their – and therefore also our –

affected stakeholders.

Å When performing desk research about our clients we use sources that track a vast amount

of updates on business impacts on the ground. We are also looking at initiatives that enable

direct feedback from workers in the supply chains of ABN AMRO’s clients. We believe that

digital connectivity is part of the solution to addressing the lack of geographical proximity.

Å We rely on the expertise of NGOs that have an extensive network in countries where our clients

operate. Several of these NGOs are party to the Dutch Banking Sector Agreement on international

responsible business conduct regarding human rights, which ABN AMRO signed in October 2016.

Å We have established a partnership with Global March and the Hague Institute for Global Justice

on the issue of human trafficking.

Eefje de Volder

Advisor Combatting

Human Trafficking,

CoMensha

Our dialogue has shown that ABN AMRO practises what it preaches by ensuring that the policies it has in place are implemented. Since labour exploitation can occur in large-scale projects that require financing, financial institutions play an important role in addressing it. CoMensha feels the momentum is now there for ABN AMRO to take a leading role and to motivate other banks to jointly determine best strategies (including through dialogue with clients) to effectively contribute to preventing or halting labour exploitation.

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Our role as an investment services provider

Labour rights and land-related human rightsABN AMRO and its clients are exposed to the human rights risks of the companies in its investment

universe. This term refers to all companies that our clients could invest in using our investment

advice. As the bank finances some of these companies as well, we also have a responsibility as

a lender to address potentially adverse human rights impacts. The Investment Products & Services

Policy defines how ABN AMRO’s investment activities are managed to ensure that they are in

accordance with the bank’s sustainability risk principles. Human rights issues are an important part of

this. All investments are screened against two lists:

Our role: ABN AMRO provides clients with products and services so that they can reach their

investment objectives. We invest assets on behalf of our clients, who can invest in three ways:

on their own (self-directed investing or execution-only), through ABN AMRO based on our

experts’ advice (investing with advice), or by leaving all investment decisions to the bank

(giving ABN AMRO a mandate). In this role, we have a financial relationship with the companies

we invest in. This gives us leverage to contribute to the mitigation of labour rights and land-

related human rights abuses.

Salient issues: Labour rights and land-related human rights.

Who could be impacted: All people who are directly or indirectly affected by the activities

of companies invested in.

Example of our impact: To prevent a situation where workers at a company in which clients

of ABN AMRO have invested are not allowed to join a trade union and bargain collectively.

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Our salient issues and roles as a bank / Our role as an investment services provider

Our role as an investment services provider

1. The Controversial Weapons List (CWL) is a list of companies that are excluded because of their – direct or indirect – involvement in

the production of dedicated components of controversial weapons (as defined by international

conventions). Having a CWL is mandatory under Dutch law.

2. The Soft Exclusion List, which comprises companies with which the bank has unsuccessfully engaged about concerns

regarding their sustainability performance.

Clients managing their investment portfolios at their own discretion will not be allowed to invest

in companies mentioned in the CWL and will be recommended not to invest in companies on the

Soft Exclusion List. In addition, ABN AMRO will not provide investment advice regarding these assets

and ABN AMRO’s investment funds will not have a position in assets that are on either of these lists.

Our influence thus varies depending on the type of investment services provided. Sustainability is

an important topic in the ABN AMRO Investment Academy, the training programme for investment

specialists and advisors. By advising clients on the investment decisions they make, these colleagues

play an important role in the successful implementation of our sustainability strategy. ABN AMRO

extends its influence by exercising its voting rights where it has a mandate to vote on behalf of

clients or fund participants.

Dilemma Companies in ABN AMRO’s investment universe may also be clients of the bank. This could

create difficulties when determining our approach towards adverse human rights impacts.

It is more difficult to end our relationship with a client than to exclude companies from our

investment universe. In 2012 we established an Investment Engagement Committee to discuss

the dilemmas the bank encounters in practice. It is composed of two Managing Board members

and representatives from the bank’s various businesses. The Committee reviews the composition

of the bank’s Soft Exclusion List, approves the Controversial Weapons List and discusses

the Sustainability Indicator scores. It also discusses progress made in engaging with companies

and decides when to start or discontinue an engagement process.

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An example from the field Anniek Mauser, Sustainability Director, Unilever Benelux:

‘ The ABN AMRO Sustainability Indicator for investments for Unilever was downgraded in 2015.

This change was a reason for us to start a dialogue with ABN AMRO and Sustainalytics to

provide more insight into our approach, challenges, and opportunities. Sustainalytics’ change

was triggered following a BBC documentary in September 2015 that raised concerns about

poor working conditions at tea plantations in Assam, India. We were very concerned about the

allegations raised at the time and worked closely with both our supplier and Rainforest Alliance

to ensure all allegations were immediately addressed. We continue to meet with our supplier

on a regular basis to review progress. We believe that the most

effective way to address labour, safety and housing standards

across the tea industry is for all parties to work together

to find a lasting solution. Although there has been

progress, we fully recognise that much remains

to be done to raise standards.’

Labour rightsABN AMRO’s own workforce, and the supply chain workforce

of corporate clients and companies we invest in on

behalf of private clients

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Our salient issues and roles as a bank / Our role as an investment services provider

Assessment of labour and land-related rights by SustainalyticsSustainalytics assesses companies against a large number of criteria, many of which are related

to human rights. Our Sustainability Risk Guide provides an overview of the criteria applied.

When assessing how a company performs on labour rights, it addresses a host of issues,

such as their:

Å Freedom of Association Policy

Å Working Conditions Policy

Å Discrimination Policy

Å Social Supplier Standards

Å Supply chain monitoring

Sustainalytics measures a company’s performance on land-related rights mainly by assessing

their Indigenous Rights Policies. It also looks at procedures, such as their overall human rights

policy in terms of due diligence, grievance mechanisms, monitoring and remedy.

Assessing the impact of companies in our investment universeDue to the scope of ABN AMRO’s investment universe it is not possible to conduct due diligence

ourselves on all companies that clients invest in. We use the expertise of external parties to gather

information on possible labour issues or land-related issues. Sustainalytics is our main source for

company analyses. It assesses companies in ABN AMRO’s investment universe on a quarterly basis.

This results in one of five possible Sustainability Indicator scores, ranging from ‘excellent’ to ‘poor’.

ABN AMRO encourages its investment advisors to draw their clients’ attention to the Sustainability

Indicator for investments, introduced by ABN AMRO in 2015. In the event of equal financial

performance, our advisors will give preference to the company that has the best sustainability rating.

Annual analysis allows us to monitor whether the performance of companies improves over time.

It also tracks structural improvements in the sustainability level of specific portfolios. In combination,

these two indicators could demonstrate to what extent the sustainability performance of our

investment products and services is improving. However, we do not yet have sufficient data to

identify a positive or negative trend.

Responding to adverse human rights impactsEngagement can take different forms, with different degrees of intensity, ranging from exerting our

voting rights to formal engagement trajectories. With regard to the latter, we decide upon engagement

when Sustainalytics determines that a company has significantly breached the principles contained

in the UN Global Compact. Engagement with companies that are clients of ABN AMRO takes place

according to the procedure described on page 28. When a company is not a client of the bank,

RobecoSAM engages on ABN AMRO’s behalf. In the latter case, companies are given three to five

years to achieve full compliance. If improvement is not deemed feasible or if a company has not

succeeded in achieving the required change within this timeframe, ABN AMRO will place the

company on the Soft Exclusion List.

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Engagement in practice An example of what constructive dialogue with an investee company looks like:

Deciding on engagementIn June 2015, ABN AMRO’s Investment Engagement Committee decided to start engaging with a

Korean company in the bank’s investment universe because of alleged breaches of the UN Global

Compact principles. Both RobecoSAM and Sustainalytics provided an analysis of the alleged breaches,

continuously monitoring the news flow of publicly available information from media, consumer

organisations and NGOs. The breaches related to forced labour and child labour by a subsidiary

of the company in the textile industry and violent clashes with local communities in India on land

issues and relocation, including corruption and bribery incidents. The company’s weak human rights

policy and limited human rights programmes were problematic in this context.

Defining objectivesEngagement starts with clear objectives. In general, RobecoSAM uses five focus areas: elimination

of the breach including compensation; policy; dialogue with affected stakeholders and sharing lessons

learned with peers; risk management systems with audit results; and transparency.

Starting a dialogueDuring an engagement period, RobecoSAM undertakes multiple interactions through emails,

letters, phone calls, meetings or shareholder meetings. In the case of this specific, Korean company:

in December 2015, after a formal letter sent by RobecoSAM, the company responded positively

by completing a written questionnaire about its human rights policies and practices. During that same

period one of RobecoSAM’s portfolio managers met with the company in Korea.

1

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Sylvia van Waveren

Senior Engagement

Specialist, RobecoSAM

Engagement involves a constructive dialogue between institutional investors and investee companies. In an engagement process, we seek to positively influence a company’s behaviour in such areas as human rights with the aim of improving its long-term performance. We see that through engagement companies gain more insight into the non-financial environmental, social and governance (ESG) factors that investors find important. In addition, they experience how ESG risks could negatively affect their reputation and, as a result, their shareholder value. We are convinced that engaging with companies on the most material sustainability issues enhances their competitiveness and profitability, as well as generating measurable benefits for investors, companies and society as a whole.

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Our salient issues and roles as a bank / Our role as an investment services provider

ResultsIn May 2016, the company informed RobecoSAM that it had established an Ethics Committee

with the aim of restoring its reputation as an ethically sound company. In addition, it introduced

bi-annual audits. This confirms the company’s increased awareness of its human rights risks.

In November 2016, RobecoSAM informed ABN AMRO that it would continue the dialogue with

the company and that, in light of these two developments, it had raised the status of the policy

objective to positive. Although positive, the results reported here for the Korean company are

just a starting point, 18 months after the start of the engagement.

Enhanced engagement typically covers a three-year period. When more than half of the objectives

have been achieved, after verification of implementation by external parties such as NGOs,

RobecoSAM may successfully close an engagement case. If a company does not improve its

ESG performance after the engagement has been concluded, the company can be excluded

from the investment universe and, as a result, put on our Soft Exclusion List by the Investment

Engagement Committee. ABN AMRO receives full and detailed information on RobecoSAM’s

engagement activities and treats this information confidentially.

Enabling investments in projects with a positive impactIn addition to providing our clients with the information they need to make the right decisions,

we offer products such as the Triodos MeesPierson mandates and the FMO Privium Impact Fund.

The former focuses on sustainable portfolio management. The latter fund enables ABN AMRO

clients to invest in projects in emerging countries through the Dutch development bank FMO.

We acknowledge that human rights violations may occur in these countries. In the past, FMO also

experienced serious challenges in this respect. We are aware of this and realise that each human

rights due diligence process may have weaknesses. Nevertheless, we have opted to partner with

FMO because of their experience in this area and how they handle these dilemmas and challenges.

4

FMO standards on human rights are set forth in our Position Statement on Human Rights. In line with the United Nations Guiding Principles on Business and Human Rights we assess human rights impacts as part of our due diligence process. The standards also apply to the portfolio of the FMO Privium Impact Fund, of course. FMO is aware of the impact of projects that involve the purchase or use of land and takes appropriate responsibility in countries where land rights are not always clearly defined. FMO is in favour of its clients obtaining land based on the ‘willing buyer/willing seller’ principle, in which case there is no threat of expropriation. In all instances, the protection of the human rights of those affected by changing land rights must be ensured. When projects affect indigenous peoples, FMO requires its clients to have a Free, Prior and Informed Consent process in place. But we also face dilemmas. For example, how do you know that a particular pressure group represents a particular issue or group of people and how do you deal with this? The FMO Privium Impact Fund measures and reports the impact of its investments, such as the number of jobs that are created. It does so based on the FMO Impact Model.

Nic Wessemius

Business Development Manager, FMO Investment Management

37

Employer

Service providerLender

Investment

services provider

Remedy

Remedy procedures for our clientsABN AMRO has an extensive grievance procedure in

place for its clients. The procedures do not distinguish

between different types of complaints. Any existing

or potential client can file a privacy or discrimination

complaint through various channels: our website,

by email, at one of our branches, or by contacting our

call centre. In our policy on complaints management,

we set out the rules and guidelines for ABN AMRO

employees on how to engage with clients who have

a complaint. Additionally, it explains our obligation

to inform our clients about our complaints procedure.

The bank registers all complaints. Most complaints are

immediately resolved. More difficult ones are handled by

the bank’s central Complaints Management Department.

If a complaint is not resolved satisfactorily by ABN AMRO,

clients can choose to file a privacy or discrimination

complaint at an institute like the Netherlands Institute

for Human Rights or the Belgian Interfederal Centre

for Equal Opportunities (Unia). Lastly, complaints may

be filed with KiFiD, the independent complaints institute

for the Dutch financial services sector. KiFiD is financed

by the affiliated banks, insurance companies and other

financial services providers, but its complaints handling

is fully independent. The rules of procedure specify that

privacy complaints may be filed by individuals regardless

of whether they are a client of a particular financial

institution. In 2015 and 2016, one privacy-related

complaint was filed against ABN AMRO, but it was

rejected by KiFiD.

The UN Guiding Principles state that companies should have processes in place to enable effective remedy for people harmed by any adverse human rights impacts the companies cause or to which they contribute. This responsibility does not exist when the company is merely linked to impacts (see page 6) for an explanation of the ‘cause, contribute, and linked to’ scenarios). ABN AMRO has remedy procedures in place for its clients and employees. In our role as a service provider and employer, it is undisputed that we may cause or contribute to human rights impacts.

38

Remedy

Remedy

Please refer to our list of online sources

on page 43 for related information

Remedy procedures for our employeesABN AMRO has a complaints procedure in every country

in which it operates. The Employee Complaints and

Grievances Policy outlines the minimum requirements

that all local procedures have to comply with. In the

Netherlands, employees can contact independent

confidential counsellors for advice and mediation

services. No distinction is made between complaints

relating to our salient human rights issues and other

complaints. ABN AMRO also has a whistleblowing

system to enable employees to report irregularities of

a general, operational or financial nature. Discrimination

is explicitly listed among the issues that may be reported.

Our International Framework Agreement (IFA) with the

Dutch trade union confederation FNV and UNI Global

Union also provides for an additional escalation procedure

for complaints by the FNV or UNI Global Union. If an issue

cannot be resolved by national or regional management

it is submitted to ABN AMRO’s Global Human Resources

Director. If the issue remains unresolved, it can be

submitted to the IFA monitoring group. Eventually, the

parties could appoint a mediator. So far, no complaint

has been filed. The global self-assessment that will take

place in 2017 will also address how well acquainted

employees are with the complaints procedure.

Remediation in relation to lending and investment services As things stand now, ABN AMRO does not have

remediation procedures in place for individuals or

communities whose human rights are impacted by

companies it finances or holds shares in on behalf of

its clients. Because grievance mechanisms are essential

to the effective protection of human rights, we ask our

corporate clients and investee companies to provide

information on how they have implemented the UN

Guiding Principles in this regard. The reality is that many

companies do not yet enable effective remedy for rights

holders who are harmed by their actions or decisions.

We will pay more attention to this issue going forward.

The focus will not be on the mere existence of grievance

mechanisms but on the question how a company

verifies the effectiveness of its mechanisms. It is

essential that companies strive to prevent issues

by engaging proactively with all their stakeholders.

Insufficient stakeholder engagement and remediation

procedures are a reason for the bank to impose

conditions in client acceptance or credit proposal

procedures. We will also explore whether a grievance

mechanism at the bank in relation to our lending

activities is feasible as a last-resort option.

39

Looking to the future

When ABN AMRO decided to report according to the UNGP Reporting Framework the main purpose was not to deliver a publication, let alone a perfect one. The framework serves primarily as a tool to develop a coherent human rights programme and to identify gaps. We are proud of where we now stand. But we also acknowledge that this report contains a great deal of qualitative, sometimes anecdotal information, as well as dilemmas that remain unanswered. We have included them because we want to be transparent and because it is the starting point for further investigations and action.

During the coming years, we will further improve our

performance in relation to human rights. Implementing

the Dutch Banking Sector Agreement on Human Rights

will be key. But we also have our own list of priorities.

Various initiatives have already been mentioned, like

the global self-assessment of how we are implementing

our International Framework Agreement.

Two broader themes are common to all four of the bank’s

roles. First, we will further embed human rights in our

organisation. The bank-wide human rights body established

in 2016 will assume its role as the main governance

platform within ABN AMRO. Second, we will improve our

tracking capabilities in order to assess more systematically

whether our efforts to address our salient human rights

are effective.

Specifically, we will improve how we record and monitor

conditions we set for our corporate clients. Enhanced

tracking will also allow us to provide a better balance

between qualitative and quantitative information in our

next human rights report.

If you would like to provide feedback

on this report, please send an email

to sustainability@nl.abnamro.com.

We would very much welcome comments

from other banks, NGOs and all others who

would like to contribute to the improvement

of our human rights efforts.

Looking to the future

40

Looking to the future

ABN AMROand Human Rights

Our path towards respecting

human rights

41

The UN Guiding Principles Reporting Framework IndexTo keep this Human Rights Report as concise and relevant as possible, it includes references to other sources.

The table below details the criteria of the UNGP Reporting Framework and where relevant material can be found.

Criterion Reporting principle Where to find itUNGP RF reference

Governance Governance of respect for human rights ABN AMRO and Human Rights guide, p. 34Human Rights Report, p. 9, 21

A

Policy commitment

What does the company say publicly about its commitment to respect human rights?

Annual Report 2015, p. 67, 73, 117-118, 165ABN AMRO and Human Rights guide, p. 27International Human Rights ConferenceHuman Rights Statement Sustainable Banking Newsletter no. 2Human Rights Report, p. 9

A1

Embedding respect for human rights

How does the company demonstrate the importance it attaches to the implementation of its human rights commitment?

ABN AMRO and Human Rights guide, p. 34International Human Rights Conference

abnamro.com/human rightsHuman Rights StatementAnnual Report 2015, pp. 117-118

A2

Reporting focus

Defining the focus of reporting Annual Report 2015, pp. 117-118Human Rights Report, pp. 6-9

B

Statement of salient issues Annual Report 2015, pp. 117-118Human Rights Report, pp. 8-9

B1

Determination of salient issues Annual Report 2015, pp. 117-118Human Rights Report, pp. 8-9

B2

Choice of focal geographies Not applicable B3

Additional severe impacts Not applicable B4

Management salient issues

Management of salient human rights issues Human Rights Report, pp. 12-39 C

Specific policies

Does the company have any specific policies that address its salient human rights issues?

Sustainability Risk PolicySustainability Risk Management FrameworkHuman Rights Report, p. 12, 15-16, 19-22, 23-25, 32-33

C1

Stakeholder engagement

What is the company’s approach to engagement with stakeholders in relation to each salient human rights issue?

ABN AMRO and Human Rights guide, pp. 35-36abnamro.com/stakeholdersabnamro.com/stakeholders: Client dialogue on agri value chainabnamro.com/sustainable banking, under Reporting: Stakeholder Consultation 2015abnamro.com/sustainable banking, under Reporting: Stakeholder Engagement 2015Human Rights Report, p. 8, 13, 19-21, 31

C2

Assessing impacts

How does the company identify any changes in the nature of each salient human rights issue over time?

ABN AMRO and Human Rights guide, pp. 36-37Human Rights Report, p. 12-13, 15, 20-21, 24-30, 34-36Annual Report 2015, p. 67, 73, 117-118, 165

C3

Integrating findings, taking action

How does the company integrate its findings about each salient human rights issue into its decision-making processes and actions?

ABN AMRO and Human Rights guide, pp. 38-39 Human Rights Report, p. 12-13, 16, 18, 21-22, 27, 31, 36-37Annual Report 2015, p. 67, 73, 117-118, 165

C4

Tracking performance

How does the company know if its efforts to address each salient human rights issue are effective in practice?

ABN AMRO and Human Rights guide, p. 40, 41Human Rights Report, p. 17, 22, 27, 32, 35, 36-37

C5

Remediation How does the company enable effective remedy if people are harmed by its actions or decisions in relation to a salient human rights issue?

ABN AMRO and Human Rights guide, pp. 42-43Human Rights Report, pp. 38-39

C6

References

42

References

References

Important online sources

About ABN AMRO

Our worldwide presence

abnamro.com/en/about-abnamro/our-company/worldwide-presence/index.html

ABN AMRO and Human Rights guide 2015

abnamro.com/nl/images/Documents/040_Duurzaamheid/Publications/ABN_AMRO_and_Human_Rights.pdf

ABN AMRO’s Annual Report 2015

abnamro.com/en/images/Documents/Investor_Relations/Financial_Disclosures/2015/ABN_AMRO_Annual_Report_2015.pdf

ABN AMRO’s sustainability strategy

abnamro.com/en/sustainable-banking/strategy-and-policy/index.html

ABN AMRO’s Human Rights Statement

abnamro.com/en/images/040_Sustainabe_banking/Links_en_documenten/Documenten/Beleid_-_Human_Rights_Statement_EN.pdf

International Framework Agreement

abnamro.com/en/newsroom/newsarticles/2015/abn-amro-signs-international-agreement-with-fnv-and-uni-global-union.html

Binding Corporate Rules abnamro.nl/en/personal/overabnamro/privacy/binding-corporate-rules.html

Stakeholder dialogue reports

abnamro.com/en/sustainable-banking/stakeholders/index.html

White Paper on ‘Due Diligence Procedures with respect to Land Governance’

abnamro.com/en/images/Documents/040_Sustainable_banking/Publications/VGGT_Land_Rights_working_paper.pdf

Sustainability Risk Framework

abnamro.com/nl/images/Documents/040_Duurzaamheid/Publications/ABN_AMRO_Sustainability_Risk_Guide.pdf

Investment Products & Services Policy

abnamro.com/en/images/Documents/040_Sustainable_banking/070_Sustainability_policy/ABN_AMRO_Summary_investment_policy.pdf

ABN AMRO’s Sustainability Indicator

abnamro.com/en/newsroom/press-releases/2015/abn-amro-introduces-new-sustainability-indicator-for-investments-and-tightens-policy-on-violation-of-un-global-compact-principles.html

Sustainability Risk Guide

abnamro.com/nl/images/Documents/040_Duurzaamheid/Publications/ABN_AMRO_Sustainability_Risk_Guide.pdf

Sustainability Risk Policy for Lending

abnamro.com/en/images/040_Sustainabe_banking/Links_en_documenten/Documenten/Beleid_-_Sustainability_Risk_Policy_for_Lending_EN.pdf

Background information

UN Guiding Principles on Business and Human Rights

ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf

UN Guiding Principles Reporting Framework

ungpreporting.org

Shift shiftproject.org

Dutch Banking Sector Agreement on international responsible business conduct regarding human rights

ser.nl/nl/publicaties/overige/2010-2019/2016/dutch-banking-sector-agreement.aspx

List of abbreviations and important terms

BBC British Broadcasting Corporation

BCR Binding Corporate Rules

BSCI Business Social Compliance Initiative

CoMensha An NGO focused on helping victims of human trafficking

CWL Controversial Weapons List

ESG Environmental, Social and Governance (criteria)

FMO Nederlandse Financierings-Maatschappij voor Ontwikkelingslanden, a Dutch development bank

FPIC Free Prior and Informed Consent

IFA International Framework Agreement

IFC International Finance Corporation

LGBT Lesbian, gay, bisexual and transgender

NGO Non-governmental organisation

NIHR Netherlands Institute for Human Rights

OECD Organisation for Economic Co-operation and Development

RA Rainforest Alliance

RSPO Round Table for Sustainable Palm Oil

UAE United Arab Emirates

UN United Nations

UNGP RF United Nations Guiding Principles Reporting Framework

VGGT Voluntary Guidelines on the Responsible Governance of Tenure of Land

Grievance mechanism

A formal complaints process

Remedy Setting right a negative impact, for example through apologies, restitution, compensation as well as the prevention of harm

Salience The human rights at risk of the most severe negative impact through the company’s activities and business relationships

43

Text: ABN AMRO Group N.V.Design: DartGroup, AmsterdamPublished: December 2016 Reporting period: 1 January 2015 - 30 November 2016

ABN AMRO’s Human Rights Report 2016 is part of ABN AMRO’s integrated reporting for the year 2016

Acknowledgements